United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-453/D-94-067
August 1994
Air
ERA New Source Performance
Standards for Cold Cleaning
Machine Operations
Background Information/
Basis and Purpose Document
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COLD CLEANING MACHINE OPERATIONS
NEW SOURCE PERFORMANCE STANDARDS
BACKGROUND INFORMATION/BASIS AND PURPOSE DOCUMENT
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
Emission Standards Division
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
August 1994
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TABLE OF CONTENTS
v,
/; Chapter Page
(V
^ 1.0 INTRODUCTION ...... 1-1
i'}
N 1.1 OVERVIEW 1-1
\~,
O 2.0 COLD CLEANING MACHINE OPERATIONS 2-1
₯
2.1 COLD CLEANING MACHINES 2-1
2.1.1 Immersion Cold Cleaning Machines 2-2
2.1.2 Remote Reservoir Cleaning Machines 2-2
2.1.3 Other Cold Cleaning Machines 2-2
2.1.4 Solvents Used in Cold Cleaning Machines . .2-6
2.2 INDUSTRY PROFILE 2-6
2.2.1 Cold Cleaning Machine Manufacturers . . . .2-6
2.2.2 Cold Cleaning Machine Operations 2-6
2.3 REFERENCES 2-7
3.0 BASELINE EMISSIONS 3-1
3.1 EMISSION MECHANISMS 3-1
3.2 BASELINE EMISSIONS 3-2
3.3 REFERENCES 3-4
4.0 EMISSION REDUCTION CONTROLS 4-1
4.1 EQUIPMENT CONTROLS 4-1
4.1.1 Increased Freeboard Ratio 4-1
4.1.2 Cover 4-2
4.1.3 Drainage Rack 4-3
4.2 WORK PRACTICES 4-3
4.2.1 Reduced Room Draft 4-3
4.2.2 Cleaning/Spray Techniques 4-4
4.2.3 Parts Drainage 4-5
4.2.4 Other Miscellaneous 4-5
4.2.4.1 Solvent Transfer 4-5
4.2.4.2 Leaks 4-6
4.3 REFERENCES 4-6
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TABLE OF CONTENTS (CONTINUED)
Chapter Page
5.0 REGULATORY APPROACH . 5-1
5.1 SUMMARY OF NSPS-GENERAL 5-1
5.2 SELECTION OF SOURCE CATEGORY . ..... 5-2
5.2.1 General 5-2
5.2.2 Maintenance Machines 5-3
5.2.3 Manufacturing Machines 5-4
5.3 RATIONALE FOR THE PROPOSED STANDARD 5-4
5.3.1 Source Category to be; Regulated 5-5
5.3.2 Pollutant to be Regulated 5-5
5.3.3 Selection of Standard . 5-6
5.4 SUMMARY OF PROPOSED STANDARD ........... 5 - 8
5.5 SUMMARY OF IMPACTS 5-11
5.5.1 Environmental and Energy Impacts 5-11-
5.5.2 Cost Impacts 5-11
5.5.2.1 Typical Cleaning Machine 5-11
5.5.2.2 Nationwide Costs 5-11
5.5.2.3 Economic Impacts ......... 5-11
5.6 REFERENCES ... .......... 5-13
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1.0 INTRODUCTION
1.1 OVERVIEW
Section 111 of the Clean Air Act (Act) requires that the
Environmental Protection Agency (EPA) establish new source
performance standards (NSPS) for categories of new, modified,
and reconstructed sources that the Administrator determines
cause, or contribute significantly to, air pollution that may
reasonably be anticipated to endanger public health or
welfare. Section 111 also requires that the EPA publish a
list of such source categories, which appears at 40 CFR 60.16.
The Administrator has identified organic solvent
degreasing, of which cold cleaning machine operations are a
subset, as a source of volatile organic compound (VOC)
emissions that causes or contributes to air pollution that may
reasonably be anticipated to endanger public health or welfare
(43 FR 38875, August 31, 1978). The intent of the proposed
standards is to require new, modified, and reconstructed
immersion cold cleaning machines with surface areas greater
than or equal to 1.8 square meters (m2) (19 square feet [ft2])
to control emissions to the level achievable by the best
demonstrated system of continuous emission reduction, taking
into consideration cost of achieving such emission reduction
and any nonair quality health and environmental impact and
energy requirements. This is the standard set out under
section lll(b)(h)(1) of the Clean Air Act (Act).
New source performance standards require sources to
control emissions to the level achievable by best demonstrated
technology (BDT). The proposed NSPS for cold cleaning
machines consists of a combination of equipment and work
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practice standards that allow for the best emission control
and for enforceability.
On June 11, 1980, the EPA proposed standards of
performance for organic solvent cleaners (45 FR 39765). The
proposed standards would have limit 3d emissions of VOC, and
trichloroethylene, perchlorethylene, methylene chloride,
1,1,l-trichloroethane, and trichlorDtrifluoroethane from new,
modified, and reconstructed organic solvent cleaners. The
applicability date for that proposal was deferred
(46 FR 22768, April 21, 1981) pending notice of a later
applicability date to be published in the Federal Register.
That later notice was never published.
Since the standards of performance of organic solvent
cleaners were proposed (45 FR 39765, June 11, 1980), a
national emission standard for hazardous air pollutants for
halogenated solvent cleaners has been proposed (58 FR 62566,
November 29, 1993) and is scheduled for promulgation in
November 1994 (40 CFR, part 63, suboart T). The part 63
standards do not cover nonhalogenated VOC often used in cold
cleaning machine operations (e.g., mineral spirits, Stoddard
solvents, naphthas) . The current N;3PS proposal would amend
40 CFR Part 60, subpart JJ consisting of §§ 60.360 through
60.363 to cover those VOC used in cold cleaning machine
operations that are not covered under 40 CFR 63, subpart T.
The current NSPS proposal also proposes to withdraw the
earlier proposal for organic solvent cleaners NSPS.
The purpose of this document is to present the following:
(1) The background information gathered during the
development of the cold cleaning machine operations NSPS; and
(2) the basis and purpose for the cold cleaning machine
operations NSPS, including factual data, methodology, legal
interpretations and policy considerations.
Section 2.0 presents a descripiion of cold cleaning
machine operations, which describes the types of cold cleaning
machines and their use. Section 3.0 presents cold cleaning
machine emission mechanisms and baseline VOC emissions for
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immersion cold cleaning machines with a solvent-air interface
area larger than or equal to 1.8 m2 (19 ft2) in the fifth year
of the standard. Section 4.0 presents equipment and operating
practices emission reduction control strategies for immersion
cold cleaning machines. The basis and purpose for limiting
emissions of VOC from cold cleaning machine operations are
presented in section 5.0. This section includes the selection
of the source category, rationale for the proposed standard,
an impacts summary, and a summary of the proposed standard.
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2.0 COLD CLEANING MACHINE OPERATIONS
Cold cleaning machines use solvent at room temperature to
clean equipment and parts. During maintenance cleaning and
the routine cleaning of small parts, cold cleaning machines
are often used. The solvents primarily used in cold cleaning
machine operations are aliphatic petroleum distillates,
alcohol blends, or naphthas. Immersion carburetor cold
cleaning machines may also use halogenated HAP solvents.
Carburetor cleaning machines that use methylene chloride (MC)
blended with other solvents and additives to reduce
flammability and increase dissolving power are regulated under
the halogenated solvent cleaner national emission standards
for hazardous air pollutants (NESHAP). Cold cleaning machine
descriptions are presented in Section 2.1. Section 2.2
presents a brief industry profile.
2.1 COLD CLEANING MACHINES
There are two basic types of cold cleaning machines used
in cold cleaning machine operations: immersion and remote
reservoir cold cleaning machines. Cold cleaning machines are
generally the simplest and least expensive of solvent cleaning
machines.
Based on discussions with vendors and distributors of
cold cleaning machines, there are approximately 1,000,000
batch cold cleaning machines nationally.1 It is estimated
that approximately 90 percent of these cold cleaning machines
are remote reservoir cold cleaning nachines and 10 percent are
immersion cold cleaning machines. There are an estimated
20,000 existing immersion cold cleaning machines that have a
solvent-air interface area greater than or equal to 1.8 m2
(19 ft2) .2
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Other cold cleaning machines exist that are a combination
of both an immersion and remote-reservoir cold cleaning
machine. Cold cleaning machine types are discussed in greater
detail in the following paragraphs.
2.1.1 Immersion Cold Cleaning Machines
Figure 2-1 illustrates an immersion cold cleaning
machine. An immersion cold cleaning machine is a cleaning
machine that uses liquid solvent at a temperature below the
solvent boiling point to clean parts. The parts are cleaned
by immersing them in the solvent.
Carburetor cold cleaning machines are a type of immersion
cold cleaning machine. Figure 2-2 is a diagram of an
immersion carburetor cold cleaning machine. Emissions from
carburetor cold cleaning machines are small and are typically
well controlled. Carburetor immersion cleaning machines are
often designed to be closed during the cleaning cycle (as well"
as during downtime) which reduces evaporation losses due to
drafts and splashing of solvent.
2.1.2 Remote Reservoir Cleaning Machines
A remote reservoir machine pumps solvent through a
sink-like work area. The solvent drains back into an enclosed
container through a small drain while the parts are being
cleaned. The solvent in the enclosed container has less
evaporative losses during nonuse periods than an open cold
cleaning machine immersion tank. Figure 2-3 presents a
diagram of a remote reservoir cold cleaning machine.
2.1.3 Other Cold Cleaning Machines
Other batch cold cleaning machines are a combination of
both the immersion and remote reservoir cleaning machine
designs. Typically, this design resembles a remote reservoir
machine in that solvent is pumped through a sink-like work
area. The machine's work area contains a shelf that can be
removed. Once removed, parts can be cleaned by immersion, as
is done in an immersion cold cleaning machine. For the
.purposes of this rule, all machines that can function as an
immersion cold cleaning machine (even if they can also
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Spray
Hose
Basket
Solvent
Cover
Cleanit
Tank
Figure 2-1.' Immersion Cold Cleaning Machine
2-3
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Air Motor and
Drive Assembly
Basket
"On" and "Off"
Valve
Figure 2-2. Carburetor Cleaning Machine
2-4
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Cleaning
Sink
v
Spray
Hose
Solvent
Cover
Figure 2-3.
Reservoir Cold Cleaning Machine
2-5
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function as a remote reservoir cold cleaning machine) are
considered immersion cold cleaning machines.
2.1.4 Solvents Used in Cold Cleaning Machines
There are a number of nonhalogenated VOC solvents used in
cold cleaning machines.1 There are an estimated 1,000,000
cold cleaning machines nationally that use nonhalogenated VOC
solvents. Most of these cold cleaning machines use petroleum
distillate VOC solvents including Stoddard solvents, petroleum
naphthas, and mineral spirits.^
2.2 INDUSTRY PROFILE
2.2.1 Cold Cleaning Machine Manufacturers
The most recent available data is from a 1987 survey of
producers of cold cleaning machines by the JACA Corporation of
Fort Washington, Pennsylvania. In this survey there were
approximately 50 companies identified as supplying cold
cleaning machines to metal cleaning operations in 1986 with
approximately seven considered producers.4
2.2.2 Cold Cleaning Machine Operations
Almost 50 percent of the establishments identified as
users of nonhalogenated VOC cold cleaning machines is
accounted for by SIC 753, Automotive Repair Shops. The
SIC 753 is a heterogeneous industry consisting of seven
four-digit SIC industries. These industries are Top, Body,
and Upholstery Repair Shops and Paint Shop (SIC 7532),
Automotive Exhaust System Repair Shops (SIC 7533), Tire
Retreading and Repair Shops (SIC 7534), Automotive Glass
Replacement Shops (SIC 7536), Automotive Transmission Repair
Shops (SIC 7537), General Automotive Repair Shops (SIC 7538),
and Automotive Repair Shops, Not Elsewhere Classified
(SIC 7539).4 Automotive repair shops generally use smaller
cold cleaning machines with a solvent/air interface of 0.4 m2
(4 square feet [ft2]).5 These machines are discussed further
in section 5.2.2.
Larger immersion cold cleaning machines are typically
used in manufacturing processes. These machines tend to have
a solvent-air interface area of 1.2 m2 (13 ft2) and larger.5
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These machines are discussed in section 5.2.3. Immersion cold
cleaning machines with solvent-air interface areas larger than
or equal to 1.8 m2 (19 ft2) are also used in automotive
rebuilding and repair, and machining industries.2
Users of cold cleaning machines are provided with the
option to either purchase or lease t.heir cold cleaning machine
equipment. For many businesses and industries, leasing,
instead of purchasing cold cleaning machines is preferred.
A number of companies lease cold cleianing machines. Many
companies that lease cold cleaning machines also offer solvent
transport; and recovery and recycling services.^ One vendor
reports that their largest industrial customers are waste-
haulers which, in turn, generally rent out and service the
machines to their own customers.^
2.3 REFERENCES
1. Telecon. O'Loughlin, J., Radic.n Corporation, with
Kusz, J., Safety-Kleen Equipment Systems, April 20, 1994.
2. Facsimile from Soble, R., Graymills Corporation to Oomen,
R. , Radian Corporation. June " , 1994. Information
regarding large immersion cold cleaning machines.
3. Alternative Control Technology Document - Halogenated
Solvent Cleaners. U.S. Envirornnental Protection Agency,
Office of Air Quality Planning and Standards.
Publication No. EPA/450/3-89/020.
4. Economic Impact Analysis of the: Degreasing NESHAP
(Draft). U.S. Environmental Protection Agency, Office of
Air Quality Planning and Standa.rds. Research Triangle
Park, NC. November 1993.
5. Memorandum from Butler, W. A., and R. Pandullo, Radian
Corporation, to Beck, D. A., U.S. Environmental
Protection Agency. October 9, 1987. Cost and Cost
Effectiveness of Controlling Emissions of Nonhalogenated
Volatile Organic Components from Organic Solvent Cleaning
Operations.
6. Letter and attachments from Frs.nz, 0., Safety-Kleen
Equipment Systems, to Rosensteeil, R. E.,
U.S. Environmental Protection Agency. April 9, 1992.
Section 114 organic solvent clesaner vendor questionnaire
response.
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7. Telseon. Gionfriddo, T., Radian Corporation, with Tills,
D., Build-All Corporation, January 28, 1994.
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3.0 BASELINE EMISSIONS
There are many types of solvem: losses to the atmosphere
from a cold cleaning machine. Section 3.1 presents a
discussion of the types of solvent losses to the atmosphere
from cold cleaning machines. The baseline emissions for the
affected industry in absence of additional standards is
presented in section 3.2.
3.1 EMISSION MECHANISMS
Two significant types of emission mechanisms are solvent-
air interface losses and workload-related losses (hereinafter
called workload losses). Solvent-air interface losses during
downtime (i.e., when the cleaning machine is not being used to
clean parts) consists of solvent evaporation from liquid
solvent.
Workload losses are solvent emissions that are created or
increased by the introduction and extraction of parts during
the cleaning process and by spraying of parts during cleaning
(if sprays are used). Other potential losses that contribute
to total solvent emissions from a cold cleaning machine
include filling/draining losses, and leaks from the cleaning
machine.
The source of solvent losses from a cold cleaning machine
during downtime is evaporation from the liquid surface and
subsequent diffusion. The rate of solvent loss is solvent-
dependent and is affected by room drafts. Room drafts can
remove solvent-laden air from above the liquid surface, thus
increasing steady state evaporation rates over quiescent
conditions.
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Workload losses from cold cleaning machines are primarily
due to: (1) agitation and spraying of the solvent during
cleaning, and (2) to carry-out and subsequent evaporation of
liquid solvent on parts being removed from the machine.
Carry-out losses may be substantially reduced by allowing
longer drainage time and by tipping parts to drain solvent -
filled cavities before removal from the cleaning machine.
Agitation can increase evaporation from the solvent bath
by increasing the effective solvent-air interface area. The
amount of solvent loss depends on the rate of agitation.
Spraying can increase the amount of solvent evaporation by
exposing more solvent to the air. The amount of solvent loss
from spraying depends on the spray pressure (which influences
turbulence and splashing).
3.2 BASELINE EMISSIONS
Upon considering costs, emission reductions, and other
impacts, the EPA determined that BDT for remote-reservoir and
immersion cold cleaning machines with solvent-air interface
areas of less than 1.8 m2 (19 ft2} was equivalent to the
equipment design in existence in absence of a NSPS. It was
determined that additional design, work practice, monitoring,
reporting, or recordkeeping requirements were not warranted
because the cost of such requirements would be unreasonable
due to little or no emission reduction benefit. This decision
is discussed further in sections 5.2 and 5.3. Therefore, the
remainder of this section includes information for immersion
cold cleaning machines with a solvent-air interface area
larger than or equal to 1.8 m2 (19 ft2).
A baseline emissions level represents the level of
emissions control achieved by an affected industry in the
absence of additional standards. The national baseline
emissions estimate for immersion cold cleaning machines with a
solvent-air interface area greater than or equal to 1.8 m2
(19 ft2) that would be affected by the proposed NSPS in the
fifth year of the standard is 8,150 Megagrams/year (Mg/yr)
(8,965 tons per year [tpy]). This estimate is based on the
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estimated number of immersion cold cleaning machines that
would be affected by the proposed standard in the first five
years after the standard is proposed and emission factors
based on factors developed during previous regulatory-
development activity.1
Information available to determine the exact number of
cleaning machines that would be subject to the proposed
standards was very limited. The EPA estimated that the number
of machines subject to the rule in ':he fifth year after the
standard is proposed at 11,480.2 This estimate is based on
the following information:
(1) A 1994 vendor estimate of 20,000 nonhalogenated
immersion cold cleaning machines with a solvent-air interface
area of 1.8 m2 (19 ft2) or larger;3
(2) an average lifetime for these machines of
10 years.4'5 It was assumed, therefore, that 10 percent of
all cleaning machines are replaced each year by new machines.
These replacement machines would be subject to the NSPS; and
(3) industry growth.6
It is assumed that, while all new machines are subject to
the NSPS, not all of the new cleaning machines would be
affected by the NSPS. Many of these cleaning machines will be
located in counties already requiring control due to State
solvent cleaning regulations (i.e., nonattainment areas).
Some of these States have State Implementation Plan (SIP)
regulations similar to the proposed NSPS. Therefore, cold
cleaning machines in these States wore assumed to already have
controls similar to the proposed NSPS controls.
Baseline emissions represent sources that would and would
not be covered by a SIP in absence of an NSPS. No information
is available on the distribution of cleaning machines at
baseline. The EPA assumed that the distribution of cleaning
machines would be proportionate to population density. The
EPA solicits comment and data in tho proposal preamble on
whether it is reasonable to assume that the distribution of
cleaning machines is proportionate to population density.
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An uncontrolled VOC emission factor of 0.52 Mg
(0.57 tons) per year for an immersion cold cleaning machine
with a solvent-air interface area of 1.2 m2 (13 ft2) was
determined during previous regulatory development activities.1
Evaporative emissions from solvent machines tend to be
proportional to the solvent-air interface.7 Therefore, the
EPA adjusted the previously developed emission estimate based
on this variable. Adjusting this factor to reflect an
immersion cold cleaning machine with a solvent-air interface
area of 1.8 m2 (19 ft2) yields an uncontrolled VOC emission
factor of 0.78 Mg (0.86 tons), and a controlled VOC emission
factor of 0.66 Mg (0.73 tons) per immersion cleaner per year.2
The controlled emission factor assumes a 15 percent emission
reduction for those cleaning^machines at BDT.l
In 1990, an estimated 40 percent of the population lived
in attainment areas, therefore it was estimated that
40 percent of cold cleaning machines are in attainment areas.
The remaining 60 percent of cold cleaning machines are
estimated to be in nonattainment areas. To estimate
emissions, 60 percent of the estimated number of controlled
and 40 percent of the estimated number of uncontrolled
immersion cold cleaning machines that would be affected by the
proposed standard in the first 5 years of the standard were
multiplied by the appropriate controlled and uncontrolled
emission factors. These emissions estimates were then added
to determine the regulatory baseline emissions level.2 The
EPA solicits comment and data on the assignment of control
level by attainment versus nonattainment areas.
3.3 REFERENCES
1. Memorandum from Pandullo, R., and M. Hanson, Radian
Corporation, to Degreasing Project File. October 9,
1987. Emissions of Nonhalogenated Volatile Organic
Compounds from Cold Cleaners and Achievable Emission
Reductions with Applicable Controls.
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2. Memorandum from O'Loughlin, J., Radian Corporation, to
Cold Cleaning Machine Operations NSPS Project File.
August 25, 1994. Documentation of Calculations Performed
in Support of the Cold Cleaning Machine Operations NSPS.
3. Facsimile from Soble, R., Graynills Corporation to
Oomen, R., Radian corporation. June 3, 1994.
Information regarding large imnersion cold cleaning
machines.
4. Letter and attachments from Franz, 0., Safety-Kleen
Equipment Systems, to Rosensteel, R. E.,
U.S. Environmental Protection Agency. April 9, 1992.
Section 114 organic solvent cleaner vendor questionnaire
response.
5. Letter and attachments from Tills, D. J., Build-All
Corporation, to Rosensteel, R. E., U.S. Environmental
Protection Agency. January 13, 1992. Section 114
organic solvent cleaner vendor questionnaire response.
»
6. Statistical Abstract of the United States:
1991 (lllth Edition). U.S. Bureau of the Census.
Washington, DC, 1991.
7. National Emission Standards for Hazardous Air Pollutants:
Halogenated Solvent Cleaning - Background Information
Document. November 1993. U.S. Environmental Protection
Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC. EPA-453/R-93-054.
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4.0 EMISSION REDUCTION CONTROLS
There are a number of different VOC solvent loss sources
from immersion cold cleaning machines. Owners or operators of
immersion cold cleaning machines can reduce solvent losses by
the use of control equipment and implementing work practices
that target and reduce losses from each source. This section
presents solvent control strategies covering both machine
design and operating practices.
4.1 EQUIPMENT CONTROLS
Immersion cold cleaning machine evaporative emission
losses are minimized by the use of the following: an
increased freeboard ratio, cover, and internal drainage rack.
These equipment controls are typically included as part of the
standard basic equipment design for large immersion cold
cleaning machines (machines with a solvent-air surface area
greater than 1.8 m2 (19 ft2)).
4.1.1 Increased Freeboard Ratio
The freeboard height on an immersion cold cleaning
machine is the distance from the solvent level (i.e., fill
line) to the top of the cleaning machine tank walls. The
freeboard zone serves to reduce solvent-air interface losses
caused by room drafts and provides a column through which
diffusing solvent molecules must migrate before escaping into
the ambient air. A higher freeboard reduces evaporative
losses by diminishing the effects of air currents and
lengthening the diffusion column.
The relationship of freeboard height divided by the
interior width (smallest width dimension of the solvent-air
interface directly exposed to the atmosphere) of an immersion
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cold cleaning machine is referred to as the freeboard ratio
(FBR).
The EPA conducted a test on the effect of the FBR on
mineral spirit evaporative losses, as well as
1,1,l-trichloroethane and perchloroethylene. There was clear
evidence that evaporation rates were less at a FBR of 0.8 than
at 0.3 or 0.6. Increasing the FBR had greater effect on the
more volatile solvents tested.^
Tests indicated that raising the freeboard ratio from
0.3 to 0.5 for cold cleaning machines using mineral spirits
reduced emissions by 20 percent.2 Immersion cold cleaning
machines typically have a FBR of at least 0.5. Another test
conducted by the EPA indicated a 26 percent emission reduction
for cold cleaning machines when the FBR was increased from
0.3 to 0.7.1
4.1.2 Cover
Covers are used on immersion cold cleaning machines to
eliminate drafts within the freeboard area and to reduce
diffusion losses. Covers can be manually operated or
electrically powered, but are typically manual. Immersion
cold cleaning machines generally have covers that have a
fusible link. A fusible link melts and causes the cover to
close in times of extreme heat (e.g., fire). Fusible links
are standard to most of the cleaning machines in this source
category because the solvents typically used in these cleaning
machines are combustible petroleum distillate solvents
(e.g., mineral spirits, Stoddard solvents, naphthas).
Manual covers are normally prcvided as standard equipment
on an immersion cold cleaning machine. These covers are
intended to reduce cleaning machine emissions during periods
of nonuse (e.g., downtime). Covers should fit well and be
carefully operated to ensure that they do not become bent or
otherwise damaged. A cover minimizes emissions when used but
provides little, if any, emission reductions if it is not used
properly. Therefore, any VOC emissions reduction associated
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with the use of a cover is dependent on the integrity of the
cover and proper work practices.
4.1/3 Drainage Rack
Drainage racks or trays are normally provided as standard
equipment on an immersion cold cleaning machine. Racks
provided are generally internal drainage racks, however,
vendors also sell external drainage racks. If external drain
racks are used, they must be designed to lead the drainage
back to the tank, or no reduction in emissions would occur.
Internal and external drainage racks, unless properly used to
drain parts, would not typically reduce VOC solvent losses.
However, there may be some reduction in evaporation losses
because of a reduced solvent-air interface while the rack is
in place. The largest potential for minimizing emissions
through the use of an internal drainage rack would be through
proper work practice control measures delineated in
section 4.2.
4.2 WORK PRACTICES
Proper operating and maintenance practices are critical
to keep VOC emissions at a minimum. Operating and maintenance
practices to minimize VOC solvent losses include, using the
cover when parts are being cleaned by agitation or when a
cleaning machine is not in use, reducing room drafts,
cleaning/spray techniques, increased parts drainage time, and
other miscellaneous operating and maintenance practices.
4.2.1 Reduced Room Draft
Air movement over an immersion cold cleaning machine
affects the solvent emission rate by sweeping away solvent
vapors diffused into the freeboard area of the cleaning
machine. This creates turbulence in the freeboard area, which
will enhance solvent diffusion and solvent-air mixing.
Emissions from diffusion can be reduced by covering an
immersion cold cleaning machine when parts are not being
cleaned. Reducing room drafts through the use of a baffle or
by reducing room ventilation flow rate near an immersion cold
cleaning machine also reduces emissions.
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4.2.2 Cleaning/Spray Techniques
Improper cleaning/spray techniques employed by an
operator can cause VOC solvent to be forced out of the
cleaning machine or increase turbulence, which result in an
increase in evaporative losses. Spraying can increase the
amount of solvent evaporation by exposing more solvent to the
air. The amount of solvent loss from spraying depends on the
spray pressure (which influences turbulence and splashing).
Control of the delivery pressure of the spray or agitation of
parts baskets being cleaned can minimize turbulence that
contributes to evaporative losses. Agitation can increase
evaporation from the solvent bath by increasing the effective
solvent-air interface area. The amount of solvent loss
depends on the rate of agitation. Cleaning parts within the
freeboard area minimizes evaporative losses from solvent being
sprayed outside of the cleaning mac.nine. Cleaning machine
turbulence that results from the use of ultrasonics to enhance
cleaning can also be controlled to prevent splash and
excessive turbulence that can contribute to VOC solvent
evaporative losses.
Evaporative emissions tests conducted by the EPA on
different grades of mineral spirits indicated that air-
agitated and pump-agitated solvent immersion cold cleaning
machines emitted 26 grams per hour per square meter (g/hr*m2)
(0.85 ounces per hour per square feet (oz/hr*ft2)) to
49 g/hr*m2 (0.161 oz/hr*ft2) solvent-air surface interface
area. Room draft velocity during testing was controlled at
3 meters per minute (m/min) (9.8 ft/min).^ Air-agitated
cleaning machines emitted less than pump agitated cleaning
machines. Unagitated cold cleaning machines, under the same
test conditions, had emission rates ranging from 3 to
9 g/hr*m2 (0.106 to 0.318 oz/hr*ft2!.3
Emissions due to the entry and removal of parts from the
liquid solvent can be reduced with good operating practices.
One such practice is to limit the introduction rate of the
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workload in order to minimize turbulence or splash that could
contribute to diffusion losses.
4.2.3 Parts Drainacre
Parts drainage is an operating practice that can minimize
VOC solvent losses. Improper racking of parts can contribute
to solvent pooling on parts and can be carried out on the
part. There is also solvent lost by carry out on the part if
an operator does not allow enough time for a part to drain.
An adequate drainage time would allow for sufficient time for
solvent to drain off -the cleaned part and back into the
cleaning machine solvent bath. Rotation or agitation of parts
with recesses or blind holes prior to removal from the
freeboard area will displace trapped solvent. Powered
rotating baskets can also be used to limit liquid carry-out.
Cleaning porous or absorbent materials can lead to carry-out
of large quantities of solvent. Significant reduction can be
obtained if parts are drained at a minimum time of 15 seconds
or until the part visibly stops dripping, whichever is longer.
The drainage rate of solvent from metal parts and parts
baskets is a function of solvent properties (e.g., viscosity)
and the surface areas of the parts and basket. Drainage tests
conducted by the EPA indicate that the majority of solvent
drained in a total drainage period of 30 seconds was actually
drained in the first 15 s-econds. A test using mineral spirits
indicated that 91 to 98 percent of solvent drained was in the
first 15 of 30 seconds.1 This range reflects differing
workloads with different workload surface areas and
complexity. The greater the surface area and complexity of
the workload, the less percentage of solvent was drained in
the first 15 of 30 seconds. Increasing the drainage time of
the tested workloads from 5 to 15 seconds resulted in an
emission reduction of 10 percent.1
4.2.4 Other Miscellaneous
4.2.4.1 Solvent Transfer. Volatile organic compound
emission losses during transfer of solvent into and out of an
immersion cold cleaning machine can be controlled by operating
4-5
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practices. Solvent transfer operation losses can be
controlled by transferring solvent by pipe in a closed system.
Some leasers and chemical distributors/vendors have systems
that allow solvent to be pumped from a solvent drum directly
into the cleaning machine. These systems could reduce spill
and evaporative losses associated with solvent filling.
Transfer of contaminated solvent or sump bottoms from an
immersion cold cleaning machine sump to stills or waste
solvent storage container can be controlled by the use of
leak-proof couples. Transfer to a vented tank or sealed
container would also minimize emissions.
4.2.4.2 Leaks. Loss of solvent through leaks can occur
continuously (depending on where the leak is located). Leaks
can result from manufacturing defects or from machine use.
They can occur from piping connection, cracks in the machine
or tank, and gasketed portholes or viewing windows. Many
manufacturers leak-test their machines before they are sold,
but cracks can occur during shipping. If not detected and
repaired, leaks can become a major source of solvent loss.
4.3 REFERENCES
1. Solvent Drainage and Evaporative from Cold Cleaner Usage:
Test Report. U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards. Research
Triangle Park, NC. January 19''8.
2. Letter and attachments from Wesstray, W. K., Economics
Laboratory, Incorporated, to Docket No. OAQPS-78-12,
U.S. Environmental Protection Agency, October 24, 1980.
Proposed New Source Standards J'or Organic Solvent
Cleaners; 40 CFR 60 Subpart JJ (45 PR 39766-84) .
3. Evaporative Emissions Study on Cold Cleaners: Test
Report. U.S. Environmental Protection Agency, Office of
Air Quality Planning and Standards, Research Triangle
Park, NC. May 1977.
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5.0 REGULATORY APPROACH
This chapter presents the basis and purpose for limiting
emissions of VOCs from cold cleaning machine operations.
Section 5.1 provides a general summary of the NSPS.
Section 5.2 provides a discussion on the selection of the
source category. Section 5.3 presents the rationale for the
proposed standard. Section 5.4 presents an impacts summary.
Section 5.5 presents a summary of the proposed standard.
Section 5.6 presents the proposed regulatory text. References
are presented in section 5.7.
5.1 SUMMARY OF NSPS-GENERAL
New source performance standards implement section 111 of
the Act. The NSPS are issued for categories of sources that
cause, or contribute significantly to, air pollution that may
reasonably be anticipated to endanger public health or
welfare. They apply to new stationary sources of emissions,
i.e., sources whose construction, reconstruction, or
modification begins after a standard for them is proposed.
An NSPS requires these sources to control emissions to
the level achievable by "best demonstrated technology," or
"BDT," which is described as follows for equipment and work
practice standards:
...the best system of emission reduction which
(taking into consideration the cost of achieving
such reduction and any nonair quality health and
environmental impact and energy requirements) the
Administrator determines has been adequately
demonstrated. [Section 111(h)(1)].
5-1
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The proposed rulemaking is applicable to owners or
operators of immersion cold cleaning machines with a
solvent-air interface area greater than or equal to 1.8 (m2)
(19 ft2) that use nonhalogenated VCC solvents.
Under section 111(a)(5), an owner or operator is any
person who owns, leases, operates, controls, or supervises a
stationary source. Under section lll(a)(3), a stationary
source is any building, structure, facility, or installation
that emits or may emit any air pollutant. Cold cleaning
machines are typically machines that are installed at a
particular location for a period of time that may vary from
several months to several years. Cnce a machine is
manufactured, the machine's configuration does not change from
location to location. Although the machine does not emit any
air pollutant until it is actually used for cleaning it may
emit pollutants once that occurs. Therefore, a cold cleaning "
machine becomes a stationary source when it is filled with
solvent and initially positioned at the place where it will
first be used, which is the place where it may first emit VOC.
The machine remains a stationary source throughout its useful
life, even though the machine may eventually be installed at a
number of different locations. The cold cleaning machine
remains a stationary source if there is a change in ownership
or a change in operator, lessor, or lessee.
Upon proposal of a NSPS, a new source is subject to the
promulgated standard. For cold cleaning machines this means a
new source is subject to the final NSPS requirements when it
is positioned at the location where it will first be used even
if it is subsequently moved to a different location prior to
promulgation of the final NSPS. A cold cleaning machine is
also subject to NSPS requirements when it is modified or
reconstructed.
5.2 SELECTION OF SOURCE CATEGORY
5.2.1 General
The Administrator has identified organic solvent
degreasing, of which cold cleaning machine operations are a
5-2
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subset, as a source of VOC emissions that causes or
contributes to air pollution that may reasonably be
anticipated to endanger public health or welfare (43 PR 38875,
August 31, 1978). Organic solvent cleaning is a listed source
category under 40 CFR 60.16. Volatile organic compound
emissions from solvent cleaning machine operations (vapor and
cold cleaning operations) were estimated in 1975 to represent
about 4 percent of the total national VOC emissions from
stationary sources; this was the fifth largest stationary
source category for organic emissions (45 FR 39765, June 11,
1980) . Batch and in-line cleaning machines using halogenated
solvents listed under section 112(b) of the Act will be
regulated under the halogenated solvent cleaner MACT standard
under section 112(d) and (h) (scheduled for promulgation in
November, 1994). However, cold cleaning machines that use
nonhalogenated VOC solvents (mostly petroleum distillates) are"
not covered under the MACT standard. Therefore these cold
cleaning machines have been selected for control through the
development of standards of performance under section 111.
Cold cleaning machines using nonhalogenated VOC solvents
can be divided into two categories. Based on their usage,
machines are classified as either maintenance or manufacturing
machines. Most cold cleaning machines fall under the
maintenance machines category, although the manufacturing
machines are usually larger machines. A description of these
maintenance and manufacturing machines is provided below.
5.2.2 Maintenance Machines
Over 95 percent of the cleaning machines in this category
are maintenance machines. These machines are typically
located in automotive maintenance and repair shops. The
machines in this category include both immersion and remote
reservoir machines. These machines typically have a
solvent/air interface area of 0.4 m2 "(4 ft2). 1
The EPA concluded that BDT for these smaller machines is
represented by existing machine design; and no work practice
or monitoring, reporting, or recordkeeping is warranted
5-3
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because the cost of such requiremenis would be unreasonable
with little or no emission reduction benefit; therefore these
machines have no requirements in the proposed standards.
5.2.3 Manufacturing Machines
Cold cleaning machines used in manufacturing situations
tend to be the larger machines. However, it is possible that
some larger machines will be used for maintenance and repair
operations, such as in the automobile and aerospace
industries. These machines tend to be much larger than
typical maintenance machines, with solvent/air interface areas
of 1.2 m2 (13 ft2) and larger.1 The EPA determined that BDT
for machines with solvent-air interface areas of less than
1.8 m2 (19 ft2) was equivalent to t'.iQ equipment design in
existence in the absence of an NSPS. As with maintenance
cleaning machines, additional desig:i, work practice,
monitoring, reporting, or recordkeeping requirements were
determined as not being warranted because the cost of such
requirements would be unreasonable with little or no emission
reduction benefit.
The EPA determined that BDT for machines with solvent-air
interface areas of 1.8 m2 (19 ft2) or greater included
additional requirements. These requirements include work
practice and minimal reporting requirements.
5.3 RATIONALE FOR THE PROPOSED STANDARD
Under the Act there are two al:ernatives available for
establishing NSPS for stationary sources. Section 111(b)
provides for establishing emission Limitations or percentage
reductions in emissions from these sources. Section lli(h)
provides that the EPA may promulgate design equipment, work
practice, or operational standards or combination thereof,
when emission limitations or percentage reduction in emissions
are not feasible. Under section llL(h), the standards
prescribed require new, modified, a.id reconstructed cold
cleaning machines to use the best technological system of
continuous emission reduction, taki.ng into consideration cost,
non-air quality health and environmental impact, and energy
5-4
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requirements that has been adequately demonstrated. Standards
under lll(b) are similarly prescribed. The emissions from
immersion cold cleaning machines are fugitive, that is, they
are not emitted from a stack or similar opening; therefore,
the methods for measuring solvent loss are impractical because
of the length of time required to accurately determine solvent
losses and the disruption in cleaning operations that would be
necessary in order to take measurements. Therefore, the EPA
has determined that it is not feasible to enforce emission
limitations or percentage reductions in emissions for
immersion cold cleaning machines. For these reasons, an
equipment and work practice standard under section 111(h) has
been selected.
5.3.1 Source Category to be Regulated
This cleaning machine source category consists of two
basic types of solvent cleaning machines: immersion and remote
reservoir. Other existing cold cleaning machine types include
a combination of these two designs.
Batch and in-line cold cleaning machines using
halogenated HAP solvents are regulated by the halogenated
solvent cleaner NESHAP, scheduled for promulgation in
November, 1994 (40 CFR 63, subpart T) . These proposed
regulations affect all cold cleaning machines using VOC
solvents or blends that are not covered by the halogenated
solvent cleaner NESHAP.
5.3.2 Pollutant to be Regulated
Most cold cleaning machines are small maintenance
cleaning machines or parts washers that typically use mineral
spirits, Stoddard solvents, and naphtha; all of these solvents
are VOC.
Batch and in-line cold cleaning machines using
halogenated solvents listed under section 112(b) of the Act
are regulated by the halogenated solvent cleaner NESHAP,
scheduled for promulgation in November, 1994 (40 CFR 63,
subpart T). These proposed regulations affect all immersion
cold cleaning machines with a solvent-air interface area
5-5
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greater than or equal to 1.8 m2 (19 ft-2) using VOC solvents or
blends that are not covered by the halogenated solvent cleaner
NESHAP.
5.3.3 Selection of Standard
Emissions of VOC from cold cleaning machines are
controlled by the use of various equipment and work practice
control measures, singly or in a coribination. Equipment
controls include: cover, drain rack, raised freeboard, solvent
pump pressure design limits, and work practice label.
Emissions of VOC from cold cleaning machines could be reduced
by implementation of work practices.
The best system of emission control for two groups of
cold cleaning machines was selected. These two groups include
(1) small (immersion [solvent-air interface area of 0.4 m2
(4 ft2)] and remote reservoir) cold cleaning machines
generally used in maintenance operations, (2) and much larger
(solvent-air interface areas 1.2 m2 [13 ft2] and larger)
immersion cold cleaning machines thctn the typical maintenance
cold cleaning machine typically used in manufacturing
operations. The emission reduction control options are
described in section 4.0.
The BDT for small and large immersion and remote
reservoir cold cleaning machines consists of both control
equipment requirements and a series of work practices. The
BDT for immersion (small and large) cold cleaning machines
include a cover, a drain rack, a visiible fill line, a
freeboard ratio of at least 0.5, solvent pump pressure design
limits, and a work practice label. The BDT for remote
reservoir cold cleaning machines includes all of the above
equipment except for a solvent fill line and freeboard ratio
of 0.5, which are not required.
The cover must be designed to be readily opened and
closed to reduce surface evaporative: losses. External drain
racks must be designed to lead the drainage back to the tank
to reduce evaporative losses from exposure to drafts or from
solvent dripping outside of the clec.ning machine. If a cold
5-6
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cleaning machine is equipped with a parts basket, internal
hooks to permit suspension of the basket above the solvent can
be substituted for the drain rack.
For solvents with a vapor pressure of less than or equal
to 4.3 kPa (33 mm Hg or 0.6 psi) measured at 38°C (100°F), the
BDT would be a freeboard ratio of 0.5, and 0.7 if the solvent
vapor pressure is greater than 4.3 kPa (33 mm Hg or 0.6 psi)
measured at 38°C (100°F). The purpose of this is to prevent
excessive volatilization, i.e., vaporization of higher
volatility solvents. Higher freeboard ratios impede excess
vaporization of highly volatile solvents under normal
operating conditions.
Solvent pump pressure design limits, and work practice
labels detailing work practices are necessary to reduce the
potential for VOC emissions from improper work practices. The
work practices include multiple techniques designed to limit
solvent emissions from the cold cleaning machine. These work
practices are discussed in more detail in section 4.2.
Based on existing data, increasing the drain time from
5 to 15 seconds can reduce overall solvent emissions from cold
cleaning machines by about 10 percent. Although no data is
readily available on emission reductions associated with the
other work practices listed above, it is estimated that these
techniques along with the drainage requirements can reduce
overall emissions by about 15 percent-1
No additional options were analyzed due to the inability
to assign individual control efficiencies to individual
control devices and work practices. The EPA solicits comment
on other control options that should be considered for these
cleaning machines. The achievable emission reduction from
immersion cold cleaning machines is estimated to be about
15 percent. The overall reduction in solvent emissions from
cold cleaning machine operations would be 7 percent.2
Upon considering costs, emission reductions, and other
impacts, the EPA concluded that BDT for all remote reservoir
cold cleaning machines and immersion cold cleaning machines
5-7
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with a solvent-air interface smaller than 1.8 m2 (19 ft2) were
at BDT and therefore did not warrant additional requirements.
The total annualized costs of work practice and reporting
and recordkeeping requirements for a typical uncontrolled
small maintenance immersion cold cleaning machine with a
solvent-air interface area of 0.4 m2 (4 ft2) would be
approximately $299/year. The emission reduction from a small
maintenance immersion cold cleaning machine would be 0.014
Mg/yr (0.015 tons/year [tpy]), making the cost effectiveness
for machines in this category $19,3f>7/Mg ($17,597/ton) .2 The
costs would be the same for a remote reservoir cold cleaning
machine; however, emission reductions would be reduced (due to
inherently lower emissions from thiss machine) to 0.008 Mg/yr
(0.009 tpy) .2 The cost effectiveness for controlling a remote
reservoir cold cleaning machine is ^35,375/Mg ($32,159/ton).2
The EPA determined that BDT for machines with solvent-air
interface areas of 1.8 m2 (19 ft2) or greater included
additional requirements. These requirements include work
practice requirements, as well as additional minimal reporting
requirements. The cost to control an uncontrolled immersion
cold cleaning machine with a solvent:-air interface area of 1.8
m2 (19 ft2) is $283/year.2 The emission reduction for an
uncontrolled cold cleaning machine is 0.117 Mg/yr (0.129 tpy),
with a cost effectiveness of $2,420/'Mg ($2,200/ton) . The cost
of BDT for a controlled immersion cold cleaning machine of 1.8
m2 (19 ft2) is $83/year, with no associated emission
reduction.2 This cost would be incurred because of the
reporting requirements.
5.4 SUMMARY OF PROPOSED STANDARD
The proposed standards limit the emissions of
nonhalogenated VOC from new, modified, and reconstructed
immersion cold cleaning machines. The VOC solvents are used
to clean metal, plastic, fiberglass, or any other type of
material. The proposed standard is a combination of equipment
and work practice requirements. The: EPA did not propose an
emission standard because the pollutant is not emitted through
5-8
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a conveyance device. In addition, application of a
measurement methodology is not practical. Thus, the proposed
regulations consist of a combination of equipment and work
practice standards that allow for the best emission control
and for enforceability.
Equipment standards include covers, raised freeboards,
solvent pump pressure design limits, and labels specifying
work practice requirements. Work practices are required to
assure the maximum ef£ectiveness of a specific piece of
control equipment, and will further reduce solvent emissions.
These proposed standards are all pollution prevention
techniques because they encourage reuse of solvent and
minimize the solvent vapor loss from the machine.
Batch and in-line cold cleaning machines using
halogenated HAP solvents listed under section 112(b) of the
Act are regulated by the halogenated solvent cleaner NESHAP,
scheduled for promulgation in November 1994 (40 CFR 63,
subpart T). The proposed NSPS regulations would affect owners
and operators of new immersion cold cleaning machines with a
solvent-air interface greater than 1.8 m2 (19 ft2) that use VOC
solvents or solvent blends that are not covered by the
halogenated solvent cleaner NESHAP.
A summary of the proposed equipment and work practice
standards is presented in table 5-1. An owner or operator of
an applicable cold cleaning machine is required to comply with
the equipment standard and associated work practices.
Compliance with the standard is through an initial
notification report from the owner or operator demonstrating
equipment standard compliance. Information supporting
compliance equivalence may be provided by the manufacturers.
Enforcement of the work practices is through inspections by
enforcement personnel. Reporting requirements include a
yearly report of equipment standard continued compliance.
5-9
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5.5 SUMMARY OF IMPACTS
5.5.1 Environmental and Energy Impacts
This standard reduces VOC emissions by 0.117 Mg/yr
(0.120 tpy) (15 percent) for a typical uncontrolled cleaning
machine of 1.8 m2 (19 ft2). Forty percent of existing cold
cleaning machines are assumed to be uncontrolled. The typical
existing control is called the "regulatory baseline."
In the fifth year after this NSPS becomes applicable,
nationwide emissions of VOC will be decreased by 540 Mg
(594 tons) compared with projected emissions calculated for the
regulatory baseline.2
These standards do not adversely impact water quality, or
create any solid waste, noise, or radiation problems.
These proposed NSPS do not affect energy consumption for a
cleaning machine of 1.8 m2 (19 ft2) compared with a cleaning
machine of the same size being controlled at the current
regulatory baseline level.
5.5.2 Cost Impacts
5.5.2.1 Typical Cleaning Machine. Annualized control costs
for an uncontrolled cleaning machine of 1.8 m2 (19 ft2) that
would meet the proposed standards would be $283. Annualized
control costs for an uncontrolled cleaning machine controlled at
the proposed level of control would be $83. The capital cost for
control equipment to meet the recommended standards of
performance for a typical cleaning machine of 1.8 m2 (19 ft2)
would be $0.2 There is no cost because existing cleaning
machines of this size already incorporate the control equipment
required to meet BDT.
5.5.2.2 Nationwide Costs. The cumulative 5-year overall
costs of control under the proposed standards would be
$1.9 million compared to $0 under the regulatory baseline.2
5.5.2.3 Economic Impacts. The Agency has conducted an
economic analysis of the potential impact of this NSPS on the
manufacturers and users of cold cleaning machines. The Agency
used model cold cleaners and model automotive repair shops, which
comprise more than 50 percent of cold cleaning users, to evaluate
5-11
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impacts. Since there is no additional capital cost associated
with the NSPS, cold cleaning manufacturers are not directly
affected by the rule. Purchasers and lessees of new cold
cleaning machines with solvent-air interface areas of greater
than or equal to 1.8 m2 (19 ft2) located in attainment areas are
likely to be directly affected by the NSPS while purchasers and
lessees of such machines located in nonattainment areas are
likely to be subject to similar regulatory requirements under a
State Implementation Plan. The direct: effect includes changes in
operating costs and the additional cost of reporting.
The Agency estimated impacts under two alternative
scenarios. The first scenario assumes; that model facilities are
able to pass along control cost increases to consumers in the
form of price increases without losing significant market share.-
The second scenario assumes that mode!, facilities are not able to
pass along control cost increases to consumers without losing
significant market share. Under the ::irst scenario, the Agency
estimates that the price of the average automotive repair will
rise by $0.11 (1991 $) , or 0.2 percent, which is not a large
enough increase to significantly affect demand, and subsequently
employment and expansion plans. Unde:r the second scenario, model
facility after-tax profitability is estimated to decline from
4.8 percent to 4.6 percent. The model facility current ratio (a
measure of solvency indicating the number of times current assets
are able to cover current liabilitiesi is estimated to decline
from 1.85 times to 1.81 times. Neither profitability or solvency
are significantly impaired under this scenario.
Finally, the increased cost of operating new cold cleaning
machines may slow demand for new machines and increase the
incentive for substitution, thereby indirectly impacting machine
manufacturers. However, machines of :he affected size comprise
less than 2 percent of all existing machines. Therefore this
indirect effect is very small.
5-12
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5.6 REFERENCES
1. Memorandum from Pandullo, R., and M. Hanson, Radian
Corporation, to Degreasing Project File. October 9, 1987.
Emissions of Nonhalogenated Volatile Organic Compounds from
Cold Cleaners and Achievable Emission Reductions with
Applicable Controls.
2. Memorandum from O'Loughlin, J., Radian Corporation, to Cold
Cleaning Machine Operations NSPS Project File. August 25,
1994. Documentation of Calculations Performed in Support of
the Cold Cleaning Machine Operations NSPS.
3. Telecon. O'Loughlin, J., Radian Corporation, with Ashland
Chemical Company, April 1994.
5-13
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1. REPORT NO.
EPA-453/D-94-067
4. TITLE AND SUBTITLE
Background Information Doci
Document - New Source Perf
Cleaning Machine Operations
TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
2.
mient/Basis and Purpose
ormance Standards for Cold
7. AUTHOR(S)
Paul A. Almodovar
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Emission Standards Division (MD-13)
Research Triangle Park, NC 27711
12. SPONSORING AGENCY NAME AND ADDRESS
Director
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 2771 1
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
August 1994
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
II. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
!
15. SUPPLEMENTARY NOTES
EPA Project Manager: Paul A. Almodovar (919) 541-0283
16. ABSTRACT
This document includes the basis and purpose, and the background information gathered during the
development of the cold cleaning machine operations new source performance standards including factual (
data, methodology, legal interpretations and policy considerations. This document describes control
techniques for volatile organic compound (VOC) solvent emissions from inmersion cold cleaning
machines.
17.
a. DESCRIPTORS
KEY WORDS AND DOCUMENT ANALYSIS
b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Group
Cold Cleaning Air Pollution control
Inmersion Cold Cleaning Machines
Volatile Organic Compounds
Stoddard solvents, petroleum naphthas
Mineral Spirits
New Source Performance Standards
1 8. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (Report) 21. NO OF PAGES
Unclassified 38
20. SECURITY CLASS (Page) 22. PRICE
Unclassified
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago. IL 60604-3590
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